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Conflict Minerals

Materiality Assessment Topic: Supply chain human rights practices

Issue Summary

Mobile phones and other electronics contain an array of metals in small amounts that allow them to function properly. Some of these metals – in particular tin, tantalum, tungsten and gold (also known as “conflict minerals”) – have been linked to armed conflict in the Democratic Republic of the Congo (DRC) and adjoining countries (“conflict zones”). These areas have suffered devastating wars and millions of deaths for more than a decade. Metal mining in this region often uses forced labor and may financially benefit armed groups. Most metals in electronics are mined from locations outside the conflict zones and involve no known human rights violations. However, minerals from the conflict zones give cause for concern.

Our Position

Mining activities in conflict zones could involve serious human rights violations and require increased transparency. We support industry efforts to address and rectify this situation.


Our Action

As a large device retailer, we’ve actively sought to address the issue of conflict minerals from the above referenced conflict zones. Our Principles of Conduct for Suppliers confirm AT&T’s expectations that the products we sell will not contain conflict minerals that directly or indirectly finance or benefit armed groups. We reserve the right to suspend or terminate suppliers who fail to demonstrate a commitment to this expectation. AT&T works with non-governmental organizations (NGOs) and our suppliers on this issue.

In addition, we have taken the following steps:

  • We do not employ forced, compulsory or slaved labor and have the same expectation for our suppliers. Both our Human Rights Policy and Principles of Conduct for Suppliers are clear in this respect.
  • We remain involved in this issue through our membership in the Global e-Sustainability Initiative (GeSI). Through this membership and our participation in the Conflict Free Sourcing Initiative (CFSI), we support the continued development of the Conflict-Free Smelter Program and the use of the CFSI Conflict Minerals Reporting Template. Through continued collaboration with suppliers, we are committed to the responsible mining of these minerals.

AT&T has taken rigorous steps to determine the extent to which it may have reporting obligations under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act and the SEC’s rules implementing that Act (SEC Conflict Minerals Rules).

With respect to the products we sell, AT&T has put in place the following ongoing activities to identify potential reporting obligations:

  • A comprehensive conflict minerals (CM) program, which serves as the documented framework in which AT&T performs the steps required to determine the applicability of, and be in compliance with, the Securities and Exchange Commission’s rules on Conflict Minerals.
  • A working team that addresses the day-to-day activities associated with complying with the Securities and Exchange Commission’s rules on Conflict Minerals.
  • A governance committee that reviews and provides general guidance on conflict minerals compliance activities.
  • An AT&T officer steering committee that provides oversight, guidance and accountability.

To date, AT&T has not had a reporting obligation pursuant to the SEC Conflict Minerals Rules. AT&T will continue to execute the CM Program annually to identify any potential changes to our filing status.

For more information on our work with suppliers, visit the Engaging our Supply Chain issue brief.

Updated on: Aug 17, 2017

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